You are right to suggest for Operators to wait until early next year.
But what difference does Operator location have to do with anything ? It's nothing to do with safety then.
If implemented the non EU States of Registry will have Operators who are being forced to comply with a quite unintelligible EASA (non ICAO) ruling based on Operator location, which will likely leave themselves wide open still to the very real threat of insurers not paying out in the event of accident or incident. Adopting such a ridiculous ruling from outside the State of Aircraft Registry will lead to more safety violations due to having to comply with two different sets of legislation. The question will be asked as to who is the real state of oversight ? A legal minefield and one that any insurer will surely use to it's advantage.
Ops manual templates issued by the professional aviation personnel at these non EU States of Registry will seemingly be invalid then, and some Operators forced to adopt an EU states Ops manual template instead.
Originally Posted by
Contacttower
Beaver, I agree there is some lack of clarity around the issue of where the operator resides and the associated implications of that. But practically speaking, the question that should be asked is whether the operator is resident in the EU or not. If they are, then EASA rules apply, regardless of the registration of the aircraft. If outside the EU...and the aircraft is not registered in the EU, then you escape...
The deadline for resident 3rd country aircraft to comply is currently April 2016, although NCC doesn't come until August. I suspect the April deadline will get pushed back again, but I can't be sure. Might be worth waiting until early next year, and if it doesn't get moved again, get skates on to be NCC compliant.
It's also looking like sub 5.7 twin turboprops will be excepted from compliance.